Daily Archives: June 25, 2018

Superannuation Integrity Measures Bill – SG Amnesty, SG Opt-out for certain high earning employees, NALI extended to non-arm’s length expenses, LRBA changes – passes Lower House 21 June 2018

On Thursday, 21 June 2018, the Treasury Laws Amendment (2018 Superannuation Measures No. 1) Bill 2018 passed the Lower House and moved to the Senate. Prior to that, on Monday, 18 June 2018, the Senate Economics Legislation Committee has released its report and recommended the Bill be passed. The Labor Senators on the Committee, however, opposed…

PCG 2018/D4 – Anti-Hybrid Bill – ATO would not apply Part IVA to a scheme to unwind certain arrangements before the 1 January 2019 start date of the new Bill (avoiding a future ‘tax benefit’)

On Thursday, 21 June 2018, the ATO issued Draft Practical Compliance Guideline PCG 2018/D4 , which provides guidance on the ATO’s compliance approach to restructures in response to the introduction of the hybrid mismatch rules. These measures (in the Treasury Laws Amendment (Tax Integrity and Other Measures No 2) Bill 2018) address certain hybrid arrangements that…

TR 2018/5 & PCG 2018/D3 – Company residence: ‘central management and control’ test after the Bywater Investments decision

On Thursday 21 June 2018, the Commissioner issued a final ruling: TR 2018/5 and a draft Practical Compliance Guideline: PCG 2018/D3 about the ‘central management and control’ test, following the High Court decision in Bywater Investments Limited & Ors v FCT [2016] HCA 45. In this case, companies set up to be non-resident, by having…